Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax against petitioners for the years 1957, 1958, and 1959 in the respective amounts of $2,168.51, $70,372.19, and $32,789.82.
In his statutory notice of deficiency respondent made adjustments to income for 1957, 1958, and 1959, disallowing petitioners capital gains treatment on the sale of stock. The explanation of adjustments for 1957 is as follows:
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